ML19330A046

Objections to Saginaw Intervenors' Interrogatories 1-232 & 234-243

ML19330A046
Person / Time
Site:	Midland
Issue date:	04/07/1971
From:	Kendall J CURRIE & KENDALL, MIDLAND NUCLEAR POWER COMMITTEE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19330A043	List: ML19330A042 ML19330A044 ML19330A046
References
NUDOCS 8007140848
Download: ML19330A046 (2)

Text

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UNITED STATES OF AMERICA  !

ATOMIC ENERGY COMMISSION

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$ In the Matter of )

1 CONSUMERS POWER COMPANY ) Docket Nos.'50-329 and 50-330

> Midland Plant, Units 1 & 2 )

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MIDLAND NUCLEAR POWER COMMITTEE 3

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k. OBJECTIONS TO SAGINAW INTERROGATORIES-1 s

• 'Intervenor Midirnd Nuclear Power Committee, hereinaf ter "MNPC",

by its counsel, Currie and Kendall, herewith submits its objections b to the Interrogatories which have been served by mail- on March 22, 1971, F

I by Intervenors Saginaw Valley Nuclear Study Group, et al, hereinaf ter

. L "Saginaw".

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t MNPC's objections and reasons therefore are as follows:

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' As to Interrogatories 1-232, MNPC objects to same on the grounds b

t- that there is no good cause shown for this discovery or against this 1

intervenor. Further, parties other than MNPC are more well-quilified to respond to same to the extent allowable and as such these interrog-

i atories are essentially redundant, burdensome, unproductive and irrelevant.

As to Interrogatories 234 through 241, MNPC objects to same on f the grounds that each and every interrogatory attempts to elicit

( opinion not pertinent to the purpose of the within inquiry, and that no good cause is shown for same.

( As to Interrogatory 242, MNPC cbjects to same on the grounds that no good cause is shown, that MNPC has no knowledge of the alleged t

instances referred to therein, that same are not in contention at these hearings and as such, if same ever occurred, are immaterial to these

< proceedings, and that if said incidents did occur and are rele" ant, material and allowablo, that oti.cr cartics to th13 proceeding are in a

, l l better position to respend to r 2n interrovatory.

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l As to Interrogatory 243, MNPC objects to same on the grounds 1

, that no good cause is shown, that same attempts to elicit opinion not

' I pertinent to the purpose of this proceeding, that it constitutes an attempt to inquire into the meaning or effect of documents which

.- Q speak for themselves and the significance of.which will be dete,rmined s /, -

' s by this Hearing Board, and that parties other then MNPC are more well-p- _ qualified to respond to same to the extent allowable.

,[ Dated: Midland, Michigan April 7, 1971 Respectfully submitted, f

f szsnt ACf

'# CURRIE AND KENDALL

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s Counsel for Midland Nuclear Power Committee l

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